On November 02, 2016 a
Exhibit,Appendix
was filed
involving a dispute between
Chin Chung Lu,
Li Hua Lu,
Lu Holding Llc,
Wen Mei Lu,
and
Wen Fu Lu,
Wen Ying Gamba,
Yuen Hsiang Lu,
for Commercial - Other (Constructive Trust)
in the District Court of Saratoga County.
Preview
FILED: SARATOGA COUNTY CLERK 09/03/2021 12:04 PM INDEX NO. 20162946
NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021
STATE OF NEW YORK
SUPREME COURT COUNTY OF SARATOGA
WEN MEI LU, CHIN CHUNG LIN LU,
LI HUA LU AND LU HOLDING, LLC
Plaintiffs, Index No: 2016-2946
RJI No.: 45-1-2016-1480
-against-
WEN YING GAMBA, YUEN HSIANG LU,
and CHUEN LOU, LLC,
Defendants.
SECOND AMENDED ANSWER
As and for an Amended Answer to plaintiff's Verified Coniplaint, the defendants, Wen
Ying Gamba, Yuen Hsiang Lu and Chuen Lou, LLC, (hereinafter referred to as "answeiing
defendants"), by and through counsel, Phelan, Phelan & Danek, LLP, states the following upon
information and belief:
PARTIES AND VENUE
plaintiffs'
1. Answering defendants deny the allegations contained in paragraph 1 of
verified complaint for want of knowledge and infonnation sufficient to form a belief as to the
truth thereof.
plaintiffs'
2. Answering defendants deny the allegations contained in paragraph 2 of
verified complaint.
plaintiffs'
3. Answering defendants deny the allegations contained in paragraph 3 of
verified complaint for want of knowledge and information sufficient to form a belief as to the
truth thereof.
{A0$44213.1}
FILED: SARATOGA COUNTY CLERK 09/03/2021 12:04 PM INDEX NO. 20162946
NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021
plaintiffs'
4. Answering defendants deny the allegations contained in paragraph 4 of
verified complaint for want of knowledge and information sufficient to form a belief as to the
truth thereof.
plaintiffs'
5. Answering defendants deny the allegations contained in paragraph 5 of
verified complaint for want of knowledge and information sufficient to form a belief as to the
truth thereof.
plaintiffs'
6. Answering defendants deny the allegations contained in paragraph 6 of
verified complaint for want of knowledge and information sufficient to form a belief as to the
truth thereof.
plaintiffs'
7. Answering defendants deny the allegations contained in paragraph 7 of
verified complaint.
plaintiffs'
8. Answering defendants deny the allegations contained in paragraph 8 of
verified complaint for want of knowledge and information sufficient to form a belief as to the
truth thereof.
plaintiffs'
9. Answering defendants deny the allegations contained in paragraph 9 of
verified complaint for want of knowledge and information sufficient to form a belief as to the
truth thereof.
INTRODUCTION
10. Answering defendants deny the allegations contained in paragraph 10 of
plaintiffs'
verified complaint for want of knowledge and information sufficient to form a belief
as to the truth thereof,
11. Answering defendants deny the allegations contained in paragraph 11 of
plaintiffs'
verified complaint.
(A0544213.1
}
2
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NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021
12. Answering defendants deny the allegations contained in paragraph 12 of
plaintiffs'
verified complaintforwantofknowledgeandinformationsufficienttoformabelief
astothetruththereof.
13. Answering defendants deny the allegations contained in paragraph 13 of
plaintiffs'verifiedcomplaint.
14. Answering defendants deny the allegations contained in paragraph 14 of
plaintiffs'verifiedcomplaint.
15. Answering defendants deny the allegations contained in paragraph 15 of
plaintiffs'verifiedcomplaint.
16, Answering defendants deny the allegations contained in paragraph 16 of
plaintiffs'verifiedcomplaint.
17. Answering defendants deny the allegations contained in paragraph 17 of
plaintiffs'verifiedcomplaint.
18. Answering defendants deny the allegations contained in paragraph 18 of
plaintiffs'verifiedcomplaint.
19. Answering defendants admit the allegation contained in paragraph 19 of
plaintiffs'verifiedcomplaintthatGambasentathreedaynoticetoquitanddenytheremaining
allegationscontainedinparagraph19ofplaintiffs'verifiedcomplaint.
20. Answering defendants deny the allegations contained in paragraph 20 of
plaintiffs'verifiedcomplaint.
21, Answering defendants admit the allegation contained in paragraph 21 of
plaintiffs'verifiedcomplaintthatGambaownsthebeachfrontpropertyinMontaukanddenythe
remainingallegationscontainedinparagraph210fplaintiffs'verifiedcomplaint.
(A0544213.] }
3
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22. Answering defendants deny the allegations contained in paragraph 22 of
plaintiffs'verifiedcomplaint.
23. Answering defendants deny the allegations contained in paragraph 23 of
plaintiffs'verifiedcomplaint.
24. Answering defendants deny the allegations contained in paragraph 24 of
plaintiffs'verifiedcomplaint.
STATEMENTOFFACTS
TheLuFamilyUnit
25. Answering defendants deny the allegations contained in paragraph 25 of
plaintiffs'verifiedcomplaint.
26. Answering defendants deny the allegations contained in paragraph 26 of
plaintiffs'verifiedcomplaint.
27, defendants the allegations contained in paragraph 27 of
Answering deny
plaintiffs'verifiedcomplaint.
TheLuFamily'sPriorBusinessVenturesandRelevantAssets
28, Answering defendants deny the allegations contained in paragraph 28 of
plaintiffs'verifiedcomplaint.
29, Answering defendants deny the allegations contained in paragraph 29 of
plaintiffs'verifiedcomplaint.
30. Answering defendants deny the allegations contained in paragraph 30 of
plaintiffs'verifiedcomplaint.
31. Answering defendants deny the allegations contained in paragraph 31 of
plaintiffs'verifiedcomplaint
{A0544213.1
)
FILED: SARATOGA COUNTY CLERK 09/03/2021 12:04 PM INDEX NO. 20162946
I
NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021
32. Answering defendants deny the allegations contained in paragraph 32 of
plaintiffs'verifiedcomplaint.
33. Answering defendants deny the allegations contained in paragraph 33 of
plaintiffs'verifiedcomplaint.
34. Answering defendants deny the allegations contained in paragraph 34 of
plaintiffs'verifiedcomplaint.
35. Answering defendants deny the allegations contained in paragraph 35 of
plaintiffs'verifiedcomplaint.
36. Answering defendants deny the allegations contained in paragraph 36 of
plaintiffs'verifiedcomplaint.
37. Answering defendants deny the allegations contained in paragraph 37 of
plaintiffs'verifiedcomplaint.
38. Answering defendants deny the allegations contained in paragraph 38 of
plaintiffs'verifiedcomplaint.
39. Answering defendant denies the allegations contained in paragraph 39 of
plaintiffs'verifiedcomplaintforwantofknowledgeandinformationsufficienttoformabelief
astothetruththereof.
40. Answering defendants deny the allegations contained in paragraph 40 of
plaintiffs'verifiedcomplaint.
41. Answering defendants deny the allegations contained in paragraph 41 of
plaintiffs'verifiedcomplaint.
42. Answering defendants deny the allegations contained in paragraph 42 of
plaintiffs'verifiedcomplaint.
{A0544213.1
}
5
FILED: SARATOGA COUNTY CLERK 09/03/2021 12:04 PM INDEX NO. 20162946
NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021
43. Answering defendants deny the allegations contained in paragraph 43 of
plaintiffs'verifiedcomplaint.
44. Answering defendants deny the allegations contained in paragraph 44 of
plaintiffs'verifiedcomplaint.
45. Answering defendants deny the allegations contained in parustaph 45 of
plaintiffs'verifiedcomplaint.
46. Answering defendants deny the allegations contained in paragraph 46 of
plaintiffs'verifiedcomplaint.
47. Answering defendants deny the allegations contained in paragraph 47 of
plaintiffs'verifiedcomplaint.
48. Answering defendants deny the allegations contained in paragraph 48 of
plaintiffs'verifiedcomplaint.
49. Answering defendants deny the allegations contained in paragraph 49 of
plaintiffs'verifiedcomplaint.
50. Answering defendants deny the allegations contained in paragraph 50 of
plaintiffs'verifiedcomplaint.
51. Answering defendants deny the allegations contained in paragraph 51 of
plaintiffs'
verified complaint.
52. Answering defendants deny the allegations contained in paragraph 52 of
plaintiffs'
verified complaint.
53. Answering defendants deny the allegations contained in paragraph 53 of
plaintiffs'verifiedcomplaint.
(A0544213.1
}
FILED: SARATOGA COUNTY CLERK 09/03/2021 12:04 PM INDEX NO. 20162946
NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021
54. Answering defendants deny the allegations contained in paragraph 54 of
plaintiffs'verifiedcomplaint.
55. Answering defendants deny the allegations contained in paragraph 55 of
plaintiffs'verifiedcomplaint.
56. Answering defendants deny the allegations contained in paragraph 56 of
plaintiffs'verifiedcomplaint.
57. Answering defendants deny the allegations contained in paragraph 57 of
plaintiffs'verifiedcomplaint.
58. Answering defendants deny the allegations contained in paragraph 58 of
plaintiffs'verifiedcomplaint.
59. Answering defendants deny the allegations contained in paragraph 59 of
plaintiffs'verifiedcomplaint.
60. Answering defendants deny the allegations contained in paragraph 60 of
plaintiffs'verifiedcomplaint.
61. Answering defendants deny the allegations contained in paragraph 61 of
plaintiffs'verifiedcomplaint.
62. Answering defendants deny the allegations contained in paragraph 62 of
plaintiffs'verifiedcomplaint.
63. Answering defendants deny the allegations contained in paragraph 63 of
plaintiffs'verifiedcomplaint.
64. Answering defendants deny the allegations contained in paragraph 64 of
plaintiffs'verifiedcomplaint.
{ A0544213.1
)
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NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021
65. Answering defendants deny the allegations contained in paragraph 65 of
plaintiffs'verifiedcomplaint.
66. Answering defendants deny the allegations contained in paragraph 66 of
plaintiffs'verifiedcomplaint.
67. Answering defendants deny the allegations contained in paragraph 67 of
plaintiffs'verifiedcomplaint.
68. Answering defendants deny the allegations contained in paragraph 68 of
plaintiffs'verifiedcomplaint.
69. Answering defendants deny the allegations contained in paragraph 69 of
plaintiffs'verifiedcomplaint,
70, Answering defendants deny the allegations contained in paragraph 70 of
plaintiffs'verifiedcomplaint.
71. Answering defendants admit the allegation contained in paragraph 71 of
plaintiffs'
verified complaint that the deed named only Gamba as titleholder and deny the
remainingallegationscontainedinparagraph710fplaintiffs'verifiedcomplaint.
72. Answering defendants deny the allegations contained in paragraph 72 of
plaintiffs'verifiedcomplaint.
73. Answering defendants deny the allegations contained in paragraph 73 of
plaintiffs'verifiedcomplaint.
TheDuoProperty
74. Auswering defendants deny the allegations contained in paragraph 74 of
plaintiffs'verifiedcomplaint.
{A05-14213.1
}
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NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021
75. Answering defendants deny the allegations contained in paragraph 75 of
plaintiffs'verifiedcomplaint.
76, defendants admit the allegation contained in paragraph 76 of
Answering
plaintiffs'verifiedcomplaintthatGambawasnamedastitleholderfortheDuopropertyanddeny
theremainingallegationscontainedinparagraph76ofplaintiffs'verifiedcomplaint.
77. Answering defendants deny the allegations contained in paragraph 77 of
plaintiffs'verifiedcomplaint.
78. Answering defendants deny the allegations contained in paragraph 78 of
plaintiffs'verifiedcomplaint.
79. Answering defendants deny the allegations contained in paragraph 79 of
plaintiffs'verifiedcomplaint.
80. Answering defendants deny the allegations contained in paragraph 80 of
plaintiffs'verifiedcomplaintforwantofknowledgeandinformationsufficienttoformabelief
astothetruththereof.
TheHibachiProperty
81. Answering defendants deny the allegations contained in paragraph 81 of
plaintiffs'verifiedcomplaint.
82. Answering defendants deny the allegations contained in paragraph 82 of
plaintiffs'verifiedcomplaint.
83. Answering defendants deny the allegations contained in paragraph 83 of
plaintiffs'verifiedcomplaint.
84. Answering defendants deny the allegations contained in paragraph 84 of
plaintiffs'verifiedcomplaint.
(A0544213,l}
FILED: SARATOGA COUNTY CLERK 09/03/2021 12:04 PM INDEX NO. 20162946
NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021
85. Answering defendants deny the allegations contained in paragraph 85 of
plaintiffs'verifiedcomplaint.
86. defendants the allegations contained in paragraph 86 of
Answering deny
plaintiffs'verifiedcomplaint.
Severa1FamilyMembersLeavetheLuFamilyUnit
87. Answering defendants deny the allegations contained in paragraph 87 of
plaintiffs'verifiedcomplaint.
88. Answering defendants deny the allegations contained in paragraph 88 of
plaintiffs'verifiedcomplaint.
89. Answering defendants deny the allegations contained in paragraph 89 of
plaintiffs'verifiedcomplaint.
90. Answering defendants deny the allegations contained in paragraph 90 of
plaintiffs'verifiedcomplaintforwantofknowledge andinformationsufficienttoformabelief
astothetruththereof.
91. Answering defendants admit the allegations contained in paragraph 91 of
plaintiffs'verifiedcomplaintthatGambawasmarriedtoAnthonyChowanddenytheremaining
allegationscontainedinparagraph91ofplaintiffs'verifiedcomplaint.
92. Answering defendants deny the allegations contained in paragraph 92 of
plaintiffs'verifiedcomplaint.
93. Answering defendants deny the allegations contained in paragraph 93 of
plaintiffs'verifiedcomplaint.
94. Answering defendants deny the allegations contained in paragraph 94 of
plaintiffs'verifiedcomplaint.
{A0544213.1
}
FILED: SARATOGA COUNTY CLERK 09/03/2021 12:04 PM INDEX NO. 20162946
NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021
95. Answering defendants deny the allegations ceiitaliled in paragraph 95 of
plaintiffs'
verified complaint.
96. Answering defendants deny the allegations contained in paragraph 96 of
plaintiffs'
verified complaint.
97. Answering defendants deny the allegations contained in paragraph 97 of
plaintiffs'
verified complaint for want of knowledge and infonnation sufficient to form a belief
as to the truth thereof.
98. Answering defendants admit the allegation contained in paragraph 98 of
plaintiffs'
verified coniplaint that the title to the Brentwood Motel property was transferred to
plaintiffs'
Patty and deny the remaining allegations contained in paragraph 98 of verified
complaint.
99. Answering defendants deny the allegations contained in paragraph 99 of
plaintiffs'
verified complaint for want of lolowledge and information sufficient to form a belief
as to the truth thereof.
100. Answering defendants admit the allegation contained in paragraph 100 of
plaintiffs'
verified complaint that the mortgage receivable from the sold Mayfield Property was
plaintiffs'
transferred to Patty and deny the remaining allegations contained in paragraph 100 of
verified complaint.
101. Answering defendants admit the allegation contained in paragraph 101 of
plaintiffW verified complaint that the Hibachi Property was transferred to Patty and deny the
plaintiffs'
remaining allegations contained in paragraph 101 of verified complaint.
(A0544213,1
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102. Answering defendants admit the allegation contained in paragraph 102 of
plaintiffs'
verified complaint that the Hunan Garden Restaurant business was transferred to Patty
plaintiffs'
and deny the remaining allegations contained in paragraph 102 of verified complaint.
103. Answering defendants deny the allegations contained in paragraph 103 of
plaintiffs'
verified complaint for want of knowledge and information sufficient to form a belief
as to the truth thereof.
104. Answering defendants deny the allegations contained in paragraph 104 of
plaintiffs'
verified complaint.
105. Answering defendants deny the allegations contained in paragraph 105 of
plaintiffs'
verified complaint.
106. Answering defendants deny the allegations contained in paragraph 106 of
plaintiffs'
verified complaint.
107. Answering defendants deny the allegations contâined in paragraph 107 of
plaintiffs'
verified complaint for want of knowledge and information sufficient to form a belief
as to the truth thereof.
108. Answering defendants deny the allegations contained in paragraph 108 of
plaintiffs'
verified complaint for want of knowledge and information sufficient to form a belief
as to the truth thereof.
109. Answering defendants deny the allegations contained in paragraph 109 of
plaintiffs'
verified complaint for want of knowledge and information sufficient to form a belief
as to the truth thereof .
(A0$44213.1}
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NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021
110. Answering defendants deny the allegations contained in paragraph 110 of
plaintiffs'
verified complaint for want of knowledge and information sufficient to form a belief
as to the truth thereof.
111. Answering defendants deny the allegations contained in paragraph 111 of
plaintiffs'
verified complaint for want of knowledge and information sufficient to form a belief
as to the truth thereof.
112. Answering defendants deny the allegations contained in paragraph 112 of
plaintiffs'
verified complaint for want of knowledge and information sufficient to form a belief
as to the truth thereof.
The Lu Family's Ouerations After 1986
113. Answering defendants deny the allegations contained in paragraph 113 of
plaintiffs'
verified complaint.
114. Answering defendants deny the allegations contained in paragraph 114 of
plaintiffs'
verified complaint for want of knowledge and information sufficient to form a belief
as to the truth thereof.
115. Answering defendants deny the allegations contained in paragraph 115 of
plaintiffs'
verified complaint for want of knowledge and information sufficient to form a belief
as to the truth thereof.
116. Answering defendants deny the allegations contained in paragraph 116 of
plaintiffs'
verified complaint.
117. Answering defendants deny the allegations contained in paragraph 117 of
plaintiffs'
verified.
{A0544213.1
}
13
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NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021
118. Answering defendants deny the allegations contained in paragraph 118 of
plaintiffs'
verified complaint for want of knowledge and information sufficient to fonn a belief
as to the truth thereof.
119. Answering defendants deny the allegations contained in paragraph 119 of
plaintiffs'
verified complaint for want of knowledge and information sufficient to form a belief
as to the truth thereof.
120. defendants the allegations contained in paragraph 120 of
Answering deny
plaintiffs'
verified complaint for want of knowledge and information sufficient to form a belief
as to the truth thereof.
121. Answering defendants deny the allegations contained in paragraph 121 of
plaintiffs'
verified complaint.
122. Answering defendants deny the allegations contained in paragraph 122 of
plaintiffs'
verified complaint for want of knowledge and information sufficient to form a belief
as to the truth thereof.
123. Answering defendants deny the allegations contained in paragraph 123 of
plaintiffs'
verified complaint for want of knowledge and information sufficient to form a belief
as to the truth thereof.
Hither House
124. Answering defendants admit the allegation contained in paragraph 124 of
plaintiffs'
verified complaint that The Hither House property is located at 10 Lincoln Road,
Montauk, Suffolk County, and is comprised of two lots and deny the remaining allegations
plaintiffs'
contained in paragraph 124 of verified complaint.
(AOS442
13.1 }
14
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NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021
125. Answering defendants deny the allegations contained in paragraph 125 of
plaintiffs'verifiedcomplaint for want of knowledgeandinformationsufficienttofonnabelief
astothetruth thereof.
126. Answering defendants deny the allegations contained in paragraph 126 of
plaintiffs'verifiedcomplaintforwantofknowledge and information sufficient to form a belief
astothetruththereof.
127. Answering defendants deny the allegations contained in paragraph 127 of
plaintiffs'verifiedcomplaint.
128. Answering defendants deny the allegations contained in paragraph 128 of
plaintiffs'verifiedcomplaint.
129. Answering defendants deny the allegations contained in paragraph 129 of
plaintiffs'
verified complaint.
130. Answering defendents deny the allegations contained in paragraph 130 of
plaintiffs'verifiedcomplaint.
131. Answering defendants deny the allegations contained in paragraph 131 of
plaintiffs'verifiedcomplaint.
132. Answering defendants deny the allegations contained in paragraph 132 of
plaintiffs'verifiedcomplaint.
133. Answering defendants deny the allegations contained in paragraph 133 of
plaintiffs'verifiedcomplaint.
134. Answering defendants deny the allegations contained in paragraph 134 of
plaintiffs'verifiedcomplaint.
{A0544213.1
)
15
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NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021
135. Answering defendants deny the allegations contained in paragraph 135 of
plaintiffs'verifiedcomplaint.
136. Answering defendants deny the allegations contained in paragraph 136 of
plaintiffs'verifiedcomplaint.
137. Answering defendants deny the allegations contained in paragraph 137 of
plaintiffs'
verified complaint for want ofknowledgeandinformationsufficienttoformabelief
astothetruththereof.
138. Answering defendants deny the allegations contained in paragraph 138 of
plaintiffs'verifiedcomplaint.
139. Answering defendants deny the allegations contained in paragraph 139 of
plaintiffs'
verifiedcomplaint.
DefendantGamba'sPatternofFrivolousLegalAction
140. Answering defendants deny the allegations contained in paragraph 140 of
plaintiffs'verifiedcomplaint.
141. Answering defendants deny the allegations contained in paragraph 141 of
plaintiffs'verifiedcomplaint.
142. Answering defendants deny the allegations contained in paragraph 142 of
plaintiffs'verifiedcomplaint.
143. Answering defendants deny the allegations contained in paragraph 143 of
plaintiffs'
verified complaint.
144. Answering defendants deny the allegations contained in paragraph 144 of
plaintiffs'verifiedcomplaintforwantofknowledgeandinformationsufficienttoformabelief
astothetruththereof.
(A0544213.1
}
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NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021
145. Answering defendants deny the allegations contained in paragraph 145 of
plaintiffs'verifiedcomplaintforwantofknowledgeandinformationsufficienttoformabelief
astothetruththereof.
146. Answering defendants deny the allegations contained in paragraph 146 of
plaintiffs'verifiedcomplaintforwantofknowledgeandinformationsufficienttoforma belief
astothetruththereof.
147. Answering defendants deny the allegations contained in paragraph 147 of
plaintiffs'verifiedcomplaint.
148. Answering defendants deny the allegations contained in paragraph 148 of
plaintiffs'verifiedcomplaint.
149. Answering defendants deny the allegations contained in paragraph 149 of
plaintiffs'verifiedcomplaint.
150. Answering defendants deny the allegations contained in paragraph 150 of
plaintiffs'verifiedcomplaint.
151. Answering defendants deny the allegations contained in paragraph 151 of
plaintiffs'verifiedcomplaint.
152. Answering defendants deny the allegations contained in paragraph 152 of
plaintiffs'verifiedcomplaint.
153. Answering defendants deny the allegations contained in paragraph 153 of
plaintiffs'verifiedcomplaint.
154. Answering defendants deny the allegations contained in paragraph 154 of
plaintiffs'verifiedcomplaint.
{ A05442
t3.1 }
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NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021
155. Answering defendants deny the allegations contained in paragraph 155 of
plaintiffs'
verified complaint.
156. Answering defendants deny the allegations contained in paragraph 156 of
plaintiffs'
verified complaint for want of knowledge and information sufficient to form a belief
as to the truth thereof.
157. Answering defendants deny the allegations contained in paragraph 157 of
plaintiffs'
verified complaint.
158. Answering defendants deny the allegations contained in paragraph 158 of
plaintiffs'
verified complaint.
159. Answering defendmTts deny the allegations contained in pà rãgråph 159 of
plaintiffs'
verified complaint.
160. Answering defendants deny the allegations contained in paragraph 160 of
plaintiffs'
verified complaint for want of knowledge and information sufficient to form a belief
as to the truth thereof.
161. Answering defendants deny the allegations contained in paragraph 161 of
plaintiffs'
verified complaint for want of knowledge and information sufficient to form a belief
as to the truth thereof.
162. Answering defendants deny the allegations contained in paragraph 162 of
plaintiffs'
verified complaint for want of knowledgeand information sufficient to form a belief
as to the truth thereof.
163. Answering defendants deny the allegations contained in paragraph 163 of
plaintiffs'
verified complaint for want of knowledgeand information sufficient to form a belief
as to the truth thereof.
{A0544213.1
}
18
FILED: SARATOGA COUNTY CLERK 09/03/2021 12:04 PM
Document Filed Date
September 03, 2021
Case Filing Date
November 02, 2016
Category
Commercial - Other (Constructive Trust)
Status
Stayed-Court Date/Application Pending
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FILED: SARATOGA COUNTY CLERK 09/03/2021 12:04 PM INDEX NO. 20162946 NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021 STATE OF NEW YORK SUPREME COURT COUNTY OF SARATOGA WEN MEI LU, CHIN CHUNG LIN LU, LI HUA LU AND LU HOLDING, LLC Plaintiffs, Index No: 2016-2946 RJI No.: 45-1-2016-1480 -against- WEN YING GAMBA, YUEN HSIANG LU, and CHUEN LOU, LLC, Defendants. SECOND AMENDED ANSWER As and for an Amended Answer to plaintiff's Verified Coniplaint, the defendants, Wen Ying Gamba, Yuen Hsiang Lu and Chuen Lou, LLC, (hereinafter referred to as "answeiing defendants"), by and through counsel, Phelan, Phelan & Danek, LLP, states the following upon information and belief: PARTIES AND VENUE plaintiffs' 1. Answering defendants deny the allegations contained in paragraph 1 of verified complaint for want of knowledge and infonnation sufficient to form a belief as to the truth thereof. plaintiffs' 2. Answering defendants deny the allegations contained in paragraph 2 of verified complaint. plaintiffs' 3. Answering defendants deny the allegations contained in paragraph 3 of verified complaint for want of knowledge and information sufficient to form a belief as to the truth thereof. {A0$44213.1} FILED: SARATOGA COUNTY CLERK 09/03/2021 12:04 PM INDEX NO. 20162946 NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021 plaintiffs' 4. Answering defendants deny the allegations contained in paragraph 4 of verified complaint for want of knowledge and information sufficient to form a belief as to the truth thereof. plaintiffs' 5. Answering defendants deny the allegations contained in paragraph 5 of verified complaint for want of knowledge and information sufficient to form a belief as to the truth thereof. plaintiffs' 6. Answering defendants deny the allegations contained in paragraph 6 of verified complaint for want of knowledge and information sufficient to form a belief as to the truth thereof. plaintiffs' 7. Answering defendants deny the allegations contained in paragraph 7 of verified complaint. plaintiffs' 8. Answering defendants deny the allegations contained in paragraph 8 of verified complaint for want of knowledge and information sufficient to form a belief as to the truth thereof. plaintiffs' 9. Answering defendants deny the allegations contained in paragraph 9 of verified complaint for want of knowledge and information sufficient to form a belief as to the truth thereof. INTRODUCTION 10. Answering defendants deny the allegations contained in paragraph 10 of plaintiffs' verified complaint for want of knowledge and information sufficient to form a belief as to the truth thereof, 11. Answering defendants deny the allegations contained in paragraph 11 of plaintiffs' verified complaint. (A0544213.1 } 2 FILED: SARATOGA COUNTY CLERK 09/03/2021 12:04 PM INDEX NO. 20162946 NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021 12. Answering defendants deny the allegations contained in paragraph 12 of plaintiffs' verified complaintforwantofknowledgeandinformationsufficienttoformabelief astothetruththereof. 13. Answering defendants deny the allegations contained in paragraph 13 of plaintiffs'verifiedcomplaint. 14. Answering defendants deny the allegations contained in paragraph 14 of plaintiffs'verifiedcomplaint. 15. Answering defendants deny the allegations contained in paragraph 15 of plaintiffs'verifiedcomplaint. 16, Answering defendants deny the allegations contained in paragraph 16 of plaintiffs'verifiedcomplaint. 17. Answering defendants deny the allegations contained in paragraph 17 of plaintiffs'verifiedcomplaint. 18. Answering defendants deny the allegations contained in paragraph 18 of plaintiffs'verifiedcomplaint. 19. Answering defendants admit the allegation contained in paragraph 19 of plaintiffs'verifiedcomplaintthatGambasentathreedaynoticetoquitanddenytheremaining allegationscontainedinparagraph19ofplaintiffs'verifiedcomplaint. 20. Answering defendants deny the allegations contained in paragraph 20 of plaintiffs'verifiedcomplaint. 21, Answering defendants admit the allegation contained in paragraph 21 of plaintiffs'verifiedcomplaintthatGambaownsthebeachfrontpropertyinMontaukanddenythe remainingallegationscontainedinparagraph210fplaintiffs'verifiedcomplaint. (A0544213.] } 3 FILED: SARATOGA COUNTY CLERK 09/03/2021 12:04 PM INDEX NO. 20162946 NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021 22. Answering defendants deny the allegations contained in paragraph 22 of plaintiffs'verifiedcomplaint. 23. Answering defendants deny the allegations contained in paragraph 23 of plaintiffs'verifiedcomplaint. 24. Answering defendants deny the allegations contained in paragraph 24 of plaintiffs'verifiedcomplaint. STATEMENTOFFACTS TheLuFamilyUnit 25. Answering defendants deny the allegations contained in paragraph 25 of plaintiffs'verifiedcomplaint. 26. Answering defendants deny the allegations contained in paragraph 26 of plaintiffs'verifiedcomplaint. 27, defendants the allegations contained in paragraph 27 of Answering deny plaintiffs'verifiedcomplaint. TheLuFamily'sPriorBusinessVenturesandRelevantAssets 28, Answering defendants deny the allegations contained in paragraph 28 of plaintiffs'verifiedcomplaint. 29, Answering defendants deny the allegations contained in paragraph 29 of plaintiffs'verifiedcomplaint. 30. Answering defendants deny the allegations contained in paragraph 30 of plaintiffs'verifiedcomplaint. 31. Answering defendants deny the allegations contained in paragraph 31 of plaintiffs'verifiedcomplaint {A0544213.1 ) FILED: SARATOGA COUNTY CLERK 09/03/2021 12:04 PM INDEX NO. 20162946 I NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021 32. Answering defendants deny the allegations contained in paragraph 32 of plaintiffs'verifiedcomplaint. 33. Answering defendants deny the allegations contained in paragraph 33 of plaintiffs'verifiedcomplaint. 34. Answering defendants deny the allegations contained in paragraph 34 of plaintiffs'verifiedcomplaint. 35. Answering defendants deny the allegations contained in paragraph 35 of plaintiffs'verifiedcomplaint. 36. Answering defendants deny the allegations contained in paragraph 36 of plaintiffs'verifiedcomplaint. 37. Answering defendants deny the allegations contained in paragraph 37 of plaintiffs'verifiedcomplaint. 38. Answering defendants deny the allegations contained in paragraph 38 of plaintiffs'verifiedcomplaint. 39. Answering defendant denies the allegations contained in paragraph 39 of plaintiffs'verifiedcomplaintforwantofknowledgeandinformationsufficienttoformabelief astothetruththereof. 40. Answering defendants deny the allegations contained in paragraph 40 of plaintiffs'verifiedcomplaint. 41. Answering defendants deny the allegations contained in paragraph 41 of plaintiffs'verifiedcomplaint. 42. Answering defendants deny the allegations contained in paragraph 42 of plaintiffs'verifiedcomplaint. {A0544213.1 } 5 FILED: SARATOGA COUNTY CLERK 09/03/2021 12:04 PM INDEX NO. 20162946 NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021 43. Answering defendants deny the allegations contained in paragraph 43 of plaintiffs'verifiedcomplaint. 44. Answering defendants deny the allegations contained in paragraph 44 of plaintiffs'verifiedcomplaint. 45. Answering defendants deny the allegations contained in parustaph 45 of plaintiffs'verifiedcomplaint. 46. Answering defendants deny the allegations contained in paragraph 46 of plaintiffs'verifiedcomplaint. 47. Answering defendants deny the allegations contained in paragraph 47 of plaintiffs'verifiedcomplaint. 48. Answering defendants deny the allegations contained in paragraph 48 of plaintiffs'verifiedcomplaint. 49. Answering defendants deny the allegations contained in paragraph 49 of plaintiffs'verifiedcomplaint. 50. Answering defendants deny the allegations contained in paragraph 50 of plaintiffs'verifiedcomplaint. 51. Answering defendants deny the allegations contained in paragraph 51 of plaintiffs' verified complaint. 52. Answering defendants deny the allegations contained in paragraph 52 of plaintiffs' verified complaint. 53. Answering defendants deny the allegations contained in paragraph 53 of plaintiffs'verifiedcomplaint. (A0544213.1 } FILED: SARATOGA COUNTY CLERK 09/03/2021 12:04 PM INDEX NO. 20162946 NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021 54. Answering defendants deny the allegations contained in paragraph 54 of plaintiffs'verifiedcomplaint. 55. Answering defendants deny the allegations contained in paragraph 55 of plaintiffs'verifiedcomplaint. 56. Answering defendants deny the allegations contained in paragraph 56 of plaintiffs'verifiedcomplaint. 57. Answering defendants deny the allegations contained in paragraph 57 of plaintiffs'verifiedcomplaint. 58. Answering defendants deny the allegations contained in paragraph 58 of plaintiffs'verifiedcomplaint. 59. Answering defendants deny the allegations contained in paragraph 59 of plaintiffs'verifiedcomplaint. 60. Answering defendants deny the allegations contained in paragraph 60 of plaintiffs'verifiedcomplaint. 61. Answering defendants deny the allegations contained in paragraph 61 of plaintiffs'verifiedcomplaint. 62. Answering defendants deny the allegations contained in paragraph 62 of plaintiffs'verifiedcomplaint. 63. Answering defendants deny the allegations contained in paragraph 63 of plaintiffs'verifiedcomplaint. 64. Answering defendants deny the allegations contained in paragraph 64 of plaintiffs'verifiedcomplaint. { A0544213.1 ) FILED: SARATOGA COUNTY CLERK 09/03/2021 12:04 PM INDEX NO. 20162946 NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021 65. Answering defendants deny the allegations contained in paragraph 65 of plaintiffs'verifiedcomplaint. 66. Answering defendants deny the allegations contained in paragraph 66 of plaintiffs'verifiedcomplaint. 67. Answering defendants deny the allegations contained in paragraph 67 of plaintiffs'verifiedcomplaint. 68. Answering defendants deny the allegations contained in paragraph 68 of plaintiffs'verifiedcomplaint. 69. Answering defendants deny the allegations contained in paragraph 69 of plaintiffs'verifiedcomplaint, 70, Answering defendants deny the allegations contained in paragraph 70 of plaintiffs'verifiedcomplaint. 71. Answering defendants admit the allegation contained in paragraph 71 of plaintiffs' verified complaint that the deed named only Gamba as titleholder and deny the remainingallegationscontainedinparagraph710fplaintiffs'verifiedcomplaint. 72. Answering defendants deny the allegations contained in paragraph 72 of plaintiffs'verifiedcomplaint. 73. Answering defendants deny the allegations contained in paragraph 73 of plaintiffs'verifiedcomplaint. TheDuoProperty 74. Auswering defendants deny the allegations contained in paragraph 74 of plaintiffs'verifiedcomplaint. {A05-14213.1 } FILED: SARATOGA COUNTY CLERK 09/03/2021 12:04 PM INDEX NO. 20162946 NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021 75. Answering defendants deny the allegations contained in paragraph 75 of plaintiffs'verifiedcomplaint. 76, defendants admit the allegation contained in paragraph 76 of Answering plaintiffs'verifiedcomplaintthatGambawasnamedastitleholderfortheDuopropertyanddeny theremainingallegationscontainedinparagraph76ofplaintiffs'verifiedcomplaint. 77. Answering defendants deny the allegations contained in paragraph 77 of plaintiffs'verifiedcomplaint. 78. Answering defendants deny the allegations contained in paragraph 78 of plaintiffs'verifiedcomplaint. 79. Answering defendants deny the allegations contained in paragraph 79 of plaintiffs'verifiedcomplaint. 80. Answering defendants deny the allegations contained in paragraph 80 of plaintiffs'verifiedcomplaintforwantofknowledgeandinformationsufficienttoformabelief astothetruththereof. TheHibachiProperty 81. Answering defendants deny the allegations contained in paragraph 81 of plaintiffs'verifiedcomplaint. 82. Answering defendants deny the allegations contained in paragraph 82 of plaintiffs'verifiedcomplaint. 83. Answering defendants deny the allegations contained in paragraph 83 of plaintiffs'verifiedcomplaint. 84. Answering defendants deny the allegations contained in paragraph 84 of plaintiffs'verifiedcomplaint. (A0544213,l} FILED: SARATOGA COUNTY CLERK 09/03/2021 12:04 PM INDEX NO. 20162946 NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021 85. Answering defendants deny the allegations contained in paragraph 85 of plaintiffs'verifiedcomplaint. 86. defendants the allegations contained in paragraph 86 of Answering deny plaintiffs'verifiedcomplaint. Severa1FamilyMembersLeavetheLuFamilyUnit 87. Answering defendants deny the allegations contained in paragraph 87 of plaintiffs'verifiedcomplaint. 88. Answering defendants deny the allegations contained in paragraph 88 of plaintiffs'verifiedcomplaint. 89. Answering defendants deny the allegations contained in paragraph 89 of plaintiffs'verifiedcomplaint. 90. Answering defendants deny the allegations contained in paragraph 90 of plaintiffs'verifiedcomplaintforwantofknowledge andinformationsufficienttoformabelief astothetruththereof. 91. Answering defendants admit the allegations contained in paragraph 91 of plaintiffs'verifiedcomplaintthatGambawasmarriedtoAnthonyChowanddenytheremaining allegationscontainedinparagraph91ofplaintiffs'verifiedcomplaint. 92. Answering defendants deny the allegations contained in paragraph 92 of plaintiffs'verifiedcomplaint. 93. Answering defendants deny the allegations contained in paragraph 93 of plaintiffs'verifiedcomplaint. 94. Answering defendants deny the allegations contained in paragraph 94 of plaintiffs'verifiedcomplaint. {A0544213.1 } FILED: SARATOGA COUNTY CLERK 09/03/2021 12:04 PM INDEX NO. 20162946 NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021 95. Answering defendants deny the allegations ceiitaliled in paragraph 95 of plaintiffs' verified complaint. 96. Answering defendants deny the allegations contained in paragraph 96 of plaintiffs' verified complaint. 97. Answering defendants deny the allegations contained in paragraph 97 of plaintiffs' verified complaint for want of knowledge and infonnation sufficient to form a belief as to the truth thereof. 98. Answering defendants admit the allegation contained in paragraph 98 of plaintiffs' verified coniplaint that the title to the Brentwood Motel property was transferred to plaintiffs' Patty and deny the remaining allegations contained in paragraph 98 of verified complaint. 99. Answering defendants deny the allegations contained in paragraph 99 of plaintiffs' verified complaint for want of lolowledge and information sufficient to form a belief as to the truth thereof. 100. Answering defendants admit the allegation contained in paragraph 100 of plaintiffs' verified complaint that the mortgage receivable from the sold Mayfield Property was plaintiffs' transferred to Patty and deny the remaining allegations contained in paragraph 100 of verified complaint. 101. Answering defendants admit the allegation contained in paragraph 101 of plaintiffW verified complaint that the Hibachi Property was transferred to Patty and deny the plaintiffs' remaining allegations contained in paragraph 101 of verified complaint. (A0544213,1 FILED: SARATOGA COUNTY CLERK 09/03/2021 12:04 PM INDEX NO. 20162946 NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021 102. Answering defendants admit the allegation contained in paragraph 102 of plaintiffs' verified complaint that the Hunan Garden Restaurant business was transferred to Patty plaintiffs' and deny the remaining allegations contained in paragraph 102 of verified complaint. 103. Answering defendants deny the allegations contained in paragraph 103 of plaintiffs' verified complaint for want of knowledge and information sufficient to form a belief as to the truth thereof. 104. Answering defendants deny the allegations contained in paragraph 104 of plaintiffs' verified complaint. 105. Answering defendants deny the allegations contained in paragraph 105 of plaintiffs' verified complaint. 106. Answering defendants deny the allegations contained in paragraph 106 of plaintiffs' verified complaint. 107. Answering defendants deny the allegations contâined in paragraph 107 of plaintiffs' verified complaint for want of knowledge and information sufficient to form a belief as to the truth thereof. 108. Answering defendants deny the allegations contained in paragraph 108 of plaintiffs' verified complaint for want of knowledge and information sufficient to form a belief as to the truth thereof. 109. Answering defendants deny the allegations contained in paragraph 109 of plaintiffs' verified complaint for want of knowledge and information sufficient to form a belief as to the truth thereof . (A0$44213.1} FILED: SARATOGA COUNTY CLERK 09/03/2021 12:04 PM INDEX NO. 20162946 NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021 110. Answering defendants deny the allegations contained in paragraph 110 of plaintiffs' verified complaint for want of knowledge and information sufficient to form a belief as to the truth thereof. 111. Answering defendants deny the allegations contained in paragraph 111 of plaintiffs' verified complaint for want of knowledge and information sufficient to form a belief as to the truth thereof. 112. Answering defendants deny the allegations contained in paragraph 112 of plaintiffs' verified complaint for want of knowledge and information sufficient to form a belief as to the truth thereof. The Lu Family's Ouerations After 1986 113. Answering defendants deny the allegations contained in paragraph 113 of plaintiffs' verified complaint. 114. Answering defendants deny the allegations contained in paragraph 114 of plaintiffs' verified complaint for want of knowledge and information sufficient to form a belief as to the truth thereof. 115. Answering defendants deny the allegations contained in paragraph 115 of plaintiffs' verified complaint for want of knowledge and information sufficient to form a belief as to the truth thereof. 116. Answering defendants deny the allegations contained in paragraph 116 of plaintiffs' verified complaint. 117. Answering defendants deny the allegations contained in paragraph 117 of plaintiffs' verified. {A0544213.1 } 13 FILED: SARATOGA COUNTY CLERK 09/03/2021 12:04 PM INDEX NO. 20162946 NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021 118. Answering defendants deny the allegations contained in paragraph 118 of plaintiffs' verified complaint for want of knowledge and information sufficient to fonn a belief as to the truth thereof. 119. Answering defendants deny the allegations contained in paragraph 119 of plaintiffs' verified complaint for want of knowledge and information sufficient to form a belief as to the truth thereof. 120. defendants the allegations contained in paragraph 120 of Answering deny plaintiffs' verified complaint for want of knowledge and information sufficient to form a belief as to the truth thereof. 121. Answering defendants deny the allegations contained in paragraph 121 of plaintiffs' verified complaint. 122. Answering defendants deny the allegations contained in paragraph 122 of plaintiffs' verified complaint for want of knowledge and information sufficient to form a belief as to the truth thereof. 123. Answering defendants deny the allegations contained in paragraph 123 of plaintiffs' verified complaint for want of knowledge and information sufficient to form a belief as to the truth thereof. Hither House 124. Answering defendants admit the allegation contained in paragraph 124 of plaintiffs' verified complaint that The Hither House property is located at 10 Lincoln Road, Montauk, Suffolk County, and is comprised of two lots and deny the remaining allegations plaintiffs' contained in paragraph 124 of verified complaint. (AOS442 13.1 } 14 FILED: SARATOGA COUNTY CLERK 09/03/2021 12:04 PM INDEX NO. 20162946 NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021 125. Answering defendants deny the allegations contained in paragraph 125 of plaintiffs'verifiedcomplaint for want of knowledgeandinformationsufficienttofonnabelief astothetruth thereof. 126. Answering defendants deny the allegations contained in paragraph 126 of plaintiffs'verifiedcomplaintforwantofknowledge and information sufficient to form a belief astothetruththereof. 127. Answering defendants deny the allegations contained in paragraph 127 of plaintiffs'verifiedcomplaint. 128. Answering defendants deny the allegations contained in paragraph 128 of plaintiffs'verifiedcomplaint. 129. Answering defendants deny the allegations contained in paragraph 129 of plaintiffs' verified complaint. 130. Answering defendents deny the allegations contained in paragraph 130 of plaintiffs'verifiedcomplaint. 131. Answering defendants deny the allegations contained in paragraph 131 of plaintiffs'verifiedcomplaint. 132. Answering defendants deny the allegations contained in paragraph 132 of plaintiffs'verifiedcomplaint. 133. Answering defendants deny the allegations contained in paragraph 133 of plaintiffs'verifiedcomplaint. 134. Answering defendants deny the allegations contained in paragraph 134 of plaintiffs'verifiedcomplaint. {A0544213.1 ) 15 FILED: SARATOGA COUNTY CLERK 09/03/2021 12:04 PM INDEX NO. 20162946 NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021 135. Answering defendants deny the allegations contained in paragraph 135 of plaintiffs'verifiedcomplaint. 136. Answering defendants deny the allegations contained in paragraph 136 of plaintiffs'verifiedcomplaint. 137. Answering defendants deny the allegations contained in paragraph 137 of plaintiffs' verified complaint for want ofknowledgeandinformationsufficienttoformabelief astothetruththereof. 138. Answering defendants deny the allegations contained in paragraph 138 of plaintiffs'verifiedcomplaint. 139. Answering defendants deny the allegations contained in paragraph 139 of plaintiffs' verifiedcomplaint. DefendantGamba'sPatternofFrivolousLegalAction 140. Answering defendants deny the allegations contained in paragraph 140 of plaintiffs'verifiedcomplaint. 141. Answering defendants deny the allegations contained in paragraph 141 of plaintiffs'verifiedcomplaint. 142. Answering defendants deny the allegations contained in paragraph 142 of plaintiffs'verifiedcomplaint. 143. Answering defendants deny the allegations contained in paragraph 143 of plaintiffs' verified complaint. 144. Answering defendants deny the allegations contained in paragraph 144 of plaintiffs'verifiedcomplaintforwantofknowledgeandinformationsufficienttoformabelief astothetruththereof. (A0544213.1 } FILED: SARATOGA COUNTY CLERK 09/03/2021 12:04 PM INDEX NO. 20162946 NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021 145. Answering defendants deny the allegations contained in paragraph 145 of plaintiffs'verifiedcomplaintforwantofknowledgeandinformationsufficienttoformabelief astothetruththereof. 146. Answering defendants deny the allegations contained in paragraph 146 of plaintiffs'verifiedcomplaintforwantofknowledgeandinformationsufficienttoforma belief astothetruththereof. 147. Answering defendants deny the allegations contained in paragraph 147 of plaintiffs'verifiedcomplaint. 148. Answering defendants deny the allegations contained in paragraph 148 of plaintiffs'verifiedcomplaint. 149. Answering defendants deny the allegations contained in paragraph 149 of plaintiffs'verifiedcomplaint. 150. Answering defendants deny the allegations contained in paragraph 150 of plaintiffs'verifiedcomplaint. 151. Answering defendants deny the allegations contained in paragraph 151 of plaintiffs'verifiedcomplaint. 152. Answering defendants deny the allegations contained in paragraph 152 of plaintiffs'verifiedcomplaint. 153. Answering defendants deny the allegations contained in paragraph 153 of plaintiffs'verifiedcomplaint. 154. Answering defendants deny the allegations contained in paragraph 154 of plaintiffs'verifiedcomplaint. { A05442 t3.1 } FILED: SARATOGA COUNTY CLERK 09/03/2021 12:04 PM INDEX NO. 20162946 NYSCEF DOC. NO. 296 RECEIVED NYSCEF: 09/03/2021 155. Answering defendants deny the allegations contained in paragraph 155 of plaintiffs' verified complaint. 156. Answering defendants deny the allegations contained in paragraph 156 of plaintiffs' verified complaint for want of knowledge and information sufficient to form a belief as to the truth thereof. 157. Answering defendants deny the allegations contained in paragraph 157 of plaintiffs' verified complaint. 158. Answering defendants deny the allegations contained in paragraph 158 of plaintiffs' verified complaint. 159. Answering defendmTts deny the allegations contained in pà rãgråph 159 of plaintiffs' verified complaint. 160. Answering defendants deny the allegations contained in paragraph 160 of plaintiffs' verified complaint for want of knowledge and information sufficient to form a belief as to the truth thereof. 161. Answering defendants deny the allegations contained in paragraph 161 of plaintiffs' verified complaint for want of knowledge and information sufficient to form a belief as to the truth thereof. 162. Answering defendants deny the allegations contained in paragraph 162 of plaintiffs' verified complaint for want of knowledgeand information sufficient to form a belief as to the truth thereof. 163. Answering defendants deny the allegations contained in paragraph 163 of plaintiffs' verified complaint for want of knowledgeand information sufficient to form a belief as to the truth thereof. {A0544213.1 } 18 FILED: SARATOGA COUNTY CLERK 09/03/2021 12:04 PM